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Universal Wastes, May 2012

Reportedly, a porter at an automobile dealership tried to dispose 150 lamps at a household recycling center. The recycling facility, meant for households wastes, declined the shipment and then cited the facility for improper disposal of fluorescent lamps (a Universal Waste). In 2001, US EPA made changes to waste rules applying to spent mercury-containing light bulbs that would require recycling of these lamps and prohibit landfill disposal. On the national level, exemption was created for businesses that generate a combination of hazardous wastes (RCRA wastes) and universal wastes in an amount of less than 100 kilograms a month. California has enacted regulations that require all facilities, without any exemptions, to recycle Universal Wastes. In Arizona, the state exempts dealers generating less than 100kg/month of RCRA and Universal Wastes under the federal regulations but the ADEQ strongly encourages the generators, to recycle the fluorescent lamps.

UNIVERSAL WASTES ARE:

Electronic devices: Includes any electronic device that is a hazardous waste (with or

Respond to releases of universal waste or its contents; determine if spill residuals are hazardous waste

CESQUWG are not required to comply with following requirements:

Use proper labeling and markings..

Notify DTSC and/or obtain an EPA identification number.

Track shipments by keeping records of what was received and shipped (name, address, quantities) for three years

CESQUWG (Conditionally Exempt Small Quantity Universal Waste Generator): A generator who generates less than 220 pounds/month of RCRA hazardous waste. Auto dealers that generate more than 220lb/month of waste thinner lose the CESQUWG status.

Recycling or Disposal: The dealership should contact a hauler and have the waste shipped to one of the recycling facilities. The hauler can provide the dealership with an appropriate container that is properly labeled. Some recycling facilities for lamps are as follows:

Storage:Generally, the container must be closed, structurally sound, compatible, and lacking evidence of leakage, spillage, or damage. Fluorescent lamps are fragile so this would require special containers that prevent breakage or spillage. Store non-automotive type batteries in plastic bucket.

Time Limitations: Waste can be stored on-site for one year. The dealership must be able to prove that the lamps have not been stored for more than one year. Put “Start Date_______” as well on container.

Training: Employees needs to be trained for handling and disposal. The training memo on managing waste mercury lamps covers the training requirements for handling fluorescent lamps is being sent to clients by mail.

Documentation: Haulers disposing lamps are not required to have any special license or permits. Disposal documents in the form of Bill of Lading or other shipping documents are to be retained on site for a period of three years. The document that must list the record may take the form of a log, invoice, manifest, bill of lading, or other shipping document. The record for each shipment of universal waste shall include information as follows:

(1) The name and address of the dealership and the destination facility

CSI recommends that the dealership also obtain some form of written assurance from the hauler that state that the waste was indeed delivered to one of the recycling facilities as listed above. It is prudent to obtain Pollution Liability Insurance and General Liability Insurance documentation from the hauler as well.

Mailing Box Programs: Many recycling facilities use mail-in boxes to collect waste mercury lamps. The recycler sells the box at a fixed price, which includes shipping costs. The customer fills the box with waste lamps and ships it back to the recycler. Shipping paper is your proof of disposal.